ARTICLE
7 August 2025

Privacy Compliance Insights From Connecticut's First Privacy Law Settlement

SM
Sheppard Mullin Richter & Hampton

Contributor

Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
Can we take any insights from Connecticut's first settlement under the state's Data Privacy Act, reached with TicketNetwork, an online ticket marketplace? The AG concerns mirrored priorities...
United States Connecticut Privacy

Can we take any insights from Connecticut's first settlement under the state's Data Privacy Act, reached with TicketNetwork, an online ticket marketplace? The AG concerns mirrored priorities outlined in Connecticut's 2025 CTDPA Enforcement Report. This suggests that future cases may also draw from that report.

In its press release about the matter, the AG argued that the company's privacy policy was "largely unreadable," missing required consumer rights information under Connecticut's privacy law, and failed to provide a functioning mechanism for consumers to exercise their data rights even after receiving a notice of violation in late 2023.

Under the settlement, TicketNetwork has agreed to pay an $85,000 penalty, as well as to maintain records regarding the number and types of consumer rights requests received and its response timelines and outcomes—metrics the AG uses to assess compliance. As a reminder, the Connecticut cure period has now expired, but some other states still have them. Namely: Indiana, Texas, Utah, and Virginia (30 day); Tennessee (60 day); Iowa (90 day); Oregon (30 day, expires January 1, 2026); Delaware (60 day, expires January 1, 2026); and Montana (60 day, expires April 1, 2026).

It is hard to tell exactly what concerns the AG had with the privacy policy. The AG did not provide any detail in its press release. However, since the AG first began its investigation of TicketNetwork (in 2022), the company made many modifications to its privacy policy (based on a comparison of its July 1, 2025 and 2023 policies, the latter available here.) Changes included adding section headers, giving more detail about rights and information collection practices, and listing the Connecticut law by name.

Putting It Into Practice: This settlement suggests that the AG may rely on the priorities set out in its enforcement report when assessing if companies are in compliance with the Connecticut Data Privacy Act. If you have not done so already, you may want to review your organization's privacy policy, including how you describe rights to consumers.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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